CCD II raises many questions – and most of the ones we receive come from merchants who simply want to know: what exactly do I need to do now? We have collected and answered the most frequently asked questions for you. If anything is missing, or if you have a situation that is not covered here, please contact your Account Manager: we will be happy to help.
CCD II is the new EU Consumer Credit Directive (officially: Directive (EU) 2023/2225 of 18 October 2023 on credit agreements for consumers and repealing Directive 2008/48/EC), replacing the old rules from 2008. It extends consumer protection for consumer credit agreements to modern financing models such as invoice purchase, instalment purchase, zero-interest financing and short-term loans – in other words, what is now commonly referred to as “Buy Now, Pay Later” (BNPL).
From 20 November 2026. The German Bundestag adopted the implementing legislation on 17 April 2026. All necessary adjustments must be in place by the deadline.
That depends on which payment methods you offer. You are generally affected if:
You are generally not affected if:
In principle, yes: the old de minimis threshold of €200 no longer applies. However, there are important exceptions for short-term payment deferrals:
In practice, this means that an invoice purchase handled by your own accounting department and due within no more than 50 days (or 14 days if you qualify as a large online provider above the SME threshold) may still remain outside consumer credit law even after November 2026.
Normally not. CCD II applies only to consumers – that is, individuals purchasing for private purposes. If your customers are exclusively business customers, you are not affected.
The decisive factor is the purpose for which the purchase is made. A VAT ID is a strong indication that the customer is acting as a business customer, but it is not conclusive: a sole trader can still make a private purchase and therefore act as a consumer. Conversely, a freelancer without a VAT ID may still be acting as a business customer.
Mixed shops with a meaningful proportion of private customers should design their ordering process in such a way that business-customer status is properly documented (for example through a mandatory declaration field and confirmation of the commercial purpose). If in doubt, please speak briefly with us or with your legal adviser.
No – if you use Unzer as your payment service provider, the creditworthiness assessment will continue to be carried out by us. We are the lender, not you. What changes is that the assessment becomes more thorough. However, you do not need to make any technical changes – the new assessment will run in the same checkout flow as before.
A realistic assessment is this: the directive requires a more in-depth creditworthiness assessment, which in individual cases may lead to longer assessment times or more frequent declines. We have prepared our processes accordingly: the assessment runs in the background in a technically optimised way, existing customer data and previous payment experience can still be factored into the evaluation, and the conversion-relevant steps in checkout remain as lean as possible.
Based on our tests to date, we do not expect any significant impact on conversion. In the first weeks after 20 November, we will monitor conversion rates particularly closely and work with you to respond if any unusual patterns arise.
Yes, but only together with the mandatory information – and with one important new requirement. Anyone advertising financing offers must already today include the annual percentage rate (APR), the total amount payable and a representative example. That is not new.
What is new, however, is a mandatory warning notice drawing attention to the risks of taking out credit, and this must appear already in the advertising, not only in the checkout. This applies to banners, product pages, newsletters and social media ads. A statement such as “Now with 0% financing” without this information may become vulnerable to legal challenge from November 2026 onwards.
Under the standard Unzer setup, usually not, because the credit agreement is concluded between your customers and us. However, you should review:
In many cases, a brief legal review of the existing documents will be sufficient.
It will cease to apply. At first glance this may seem like a detail, but legally it is significant: until now there has been an official model notice on which lenders could rely. From 20 November 2026, lenders must draft their own legally compliant notice. For Unzer merchants, this is not a problem – as lender, we provide the legally compliant notice in the checkout. If, in addition to Unzer, you also offer your own financing models in which you act as lender, you should speak to your legal adviser.
Important by way of distinction: this concerns the model notice for the credit agreement between your customers and Unzer. Your own withdrawal notice for the purchase agreement is not affected by this change – the model for distance-selling transactions remains in place. So you do not need to rewrite your shop’s withdrawal notice because of CCD II.
Contracts concluded before 20 November 2026 will continue under the old law. The new rules apply to all new contracts concluded from the effective date onwards. You do not need to amend or migrate existing contracts.
This is good news for e-commerce: from November 2026, a consumer credit agreement may be concluded in text form – for example by email, PDF or digital document. A handwritten signature is no longer necessary. Anyone who has previously worked with hybrid processes (order online, sign on paper) can move to a fully digital process.
As a Unzer merchant: no. The changes to the creditworthiness assessment, pre-contractual information and withdrawal notice are handled through our integration. If you use our plugin or our API, you will receive the updates automatically. For most merchants, no manual code changes are required.
Barely noticeably. The new creditworthiness assessment is technically more thorough, but it still runs in milliseconds. Our internal tests show that, compared with today, the checkout process takes only a few hundred milliseconds longer. On the current view, the impact on conversion should remain limited.
Yes – but we will take care of that. From November 2026, the “Standard European Consumer Credit Information” must be displayed before the contract is concluded. Unzer will integrate this information into the existing checkout flow. You do not need to draft or maintain this information yourself.
Our plugins for the common shop systems will be updated in good time before 20 November 2026. You will receive update information by email and via our portal. Important: please make sure you install updates promptly. Merchants using a very old plugin version should plan an upgrade by September 2026 at the latest.
Possibly. If you have made extensive changes to the checkout flow (for example your own consent screens, altered sequences or custom integrations), please speak to your Unzer contact. We will review together whether your integration is compatible with the new requirements.
All reputable providers on the German market will implement the new rules. What differs is the speed, transparency and quality of the integration. Assess your current provider against the following questions:
If the answer to these questions is “no”, then a conversation with alternative providers may be worthwhile.
If you are a Unzer customer, we will take care of the main regulatory work. However, there are still three areas you should keep an eye on:
For many small and medium-sized merchants, the practical risk is likely to remain manageable – especially if the regulatory requirements are reviewed at an early stage.
For Unzer merchants, costs are low – they usually arise only from:
Merchants operating their own instalment-purchase solutions face significantly higher costs – in such cases we are more likely talking about five-figure sums for legal advice, system adjustments and process redesign.
Primarily in the area of advertising. Consumer and competition bodies will watch the new advertising obligations for financing offers closely – this is a classic area for legal challenges. Review your banners, landing pages and advertisements by October 2026 at the latest. As for the checkout process, the risk is low, because Unzer is responsible for the regulatory design.
No, there is no obligation to write to existing customers. Information in the checkout before the contract is concluded is sufficient – and we will provide that. If you would nevertheless like to communicate proactively (for example to build trust), you are welcome to do so – we can provide text modules for your use.
Three things:
Quite a lot – CCD II is not only an e-commerce issue. Traditional instalment-purchase agreements in furniture, electronics or specialist retail fall fully within its scope. The most important points include:
Händler:innen, die eigene Ratenkauf-Lösungen betreiben, haben deutlich höhere Kosten – hier sprechen wir eher über fünfstellige Beträge für Rechtsberatung, System-Anpassungen und Prozess-Redesign.
Possibly – and this should be reviewed once. Exempt are traders who carry out intermediary activities only to finance their own sales and qualify as a small or medium-sized enterprise (SME).
Larger merchants above the SME threshold, as well as platforms that arrange financing for third-party sales, should take a closer look. Specifically, this concerns Section 34k GewO, which introduces a separate authorisation requirement for the commercial brokering of consumer loans and financing assistance. Whether such authorisation is required depends on the specific structure of the business model.
If in doubt, speak to your Account Manager – we can help you classify the situation.
This is a genuine new requirement: if less than 24 hours pass between the pre-contractual information and the conclusion of the contract – which is practically always the case in online checkout – the consumer must be expressly reminded once again of their right of withdrawal and how to exercise it between one and seven days after the contract has been concluded.
For Unzer merchants, we handle this reminder as part of our standard integration. You do not need to send your own emails or intervene in your process.
The best primary sources are:
For operational questions, please refer to our Unzer portal and the CCD II guide on our website (www.unzer.com).
Your Unzer Account Manager will be happy to help. For general questions about CCD II, we recommend our blog / Highspot. General questions can also be answered via the usual support channel.